Epstein Secrets

specific documents withheld with enough detail to facilitate the evaluation of and challenges to the privileges asserted therein. TIG Ins. Cap. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001); Abbott Laboratories v. Alpha Therapeutic Corp., No. 97-C-1292, 2000 WL 1863543 (N.D. III. Dec. 14, 2000). Moreo

gs initiated by Edwards, but Edwards, himself, would be in violation of the Court's ruling by his reference to the e-mails in filings in this Court, the Appellate Court and the Bankruptcy Court. Epstein has complied fully with this Court's March 8, 2018, in-court rulings. The disc is sealed, the 47 exhibits (also r

der SORA was unsupportable under the legally mandated "clear and convincing evidence" standard. See Correction Law §§ 168.1(2), 168- n(2); People v. Johnson, 11 N.Y.3d 416, 421 (2008). B. The District Attorney's Office Appropriately Applied the Governing Legal Standard, As Set Forth by SORA and Its Gu

Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary at 5, ¶ 7 (2006). Accordingly, the Order 6 By previewing for the Appellate Court "[t]he People's evidence on remand," see Resp. Br. at 62, n. 7, the People have improperly introduced materials dehors the record. See Mount Lucas

ar and convincing evidence" standard, as the People rightfully represented at the SORA hearing. See Correction Law §§ 168-k(2), 168-n(2); People v. Johnson, 11 N.Y.3d 416, 421 (2008). 12 EFTA00798132 A. The People Rejected the Board Recommendation As Unreliable Following Several Months of Investig

he People's Attempt to Introduce Materials Outside the Record Was Improper and Reference to Such Contentions Should Be Stricken. By previewing for the Appellate Court in their brief "the People's evidence on remand," see Resp. Br. at 62, n. 7, the People have improperly introduced materials dehors the record. See

ervice List on this F te day of September 2009. 09/12/2019 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON 6 P CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331962 EFTA 00204688 EFTA02729672 Case 9:08-cv-80119-KAM Document 305 Entered on

e Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 4th DCA. If the Clerk gets no direction from the Appellate Court, she shall disclose the documents on the date referred to above. DONE AND ORDERED in West Palm Bea 1. Palm Beach County, MOM day of June, 2009.

der SORA was unsupportable under the legally mandated "clear and convincing evidence" standard. See Correction Law §§ 168- k(2), 168-n(2); People v. Johnson, 11 3d 416, 421 (2008). B. The District Attorney's Office Appropriately Applied the Governing Legal Standard, As Set Forth by SORA and Its Guide

to which Appellant ultimately pled guilty.5 Resp. Br. at 62, n. 7. By so doing, the People themselves unwittingly concede that 5 By previewing for the Appellate Court "the People's evidence on remand," see Resp. Br. at 62, n. 7, the People have improperly introduced materials dehors the record. See Mount Lucas As

Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. Fimmy1 (Rio D.C. ELECTRONIC JULY 7, 2008 savcila tARIm011t With 01ST. CT. ".A. • MIAMI Sters enc

he Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 491DCA. If the Clerk gets no direction from the Appellate Court, she shall disclose the documents on the date referred to above. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this SIGNED AND D

Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. FI cilio ELaT JULY 7, 2008 STEVEN IA. LARIUORE CLERK M.S. GIST. CS. 5.0. Or ILA. • MIAMI s,., ers e

e Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 4th DCA. If the Clerk gets no direction from the Appellate Court, she shall disclose the documents on the date referred to above. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this ::a3TJCDA74

Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07107/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. Fle-WelltitY1 ail) D.C. ELECTRUNC JULY 7, 2008 STITCH M. LARIM0Nt CLOW O.S. 0151. 5.0. OF FLA. MIAMI

e Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 4th DCA. If the Clerk gets no direction from the Appellate Court, she shall disclose the documents on the date referred to above. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this GTIKDAiti t5